The New Anti-Money Laundering Rule - Schulte Roth & Zabel

The New Anti-Money Laundering Rule

25TH ANNUAL

PRIVATE INVESTMENT FUNDS SEMINAR

JANUARY 19, 2016

Special Counsel New York Office +1 212.756.2072 brad.caswell@

Practices

Investment Management Hedge Funds Regulatory & Compliance

Brad L. Caswell

Brad focuses his practice on counseling hedge funds and private equity funds on operational, regulatory and compliance matters. He represents clients on a broad range of issues, including those related to the U.S. Investment Advisers Act, other federal, state and self-regulatory organization requirements and securities trading rules in the United States. Brad also provides guidance to clients with operations in Hong Kong, Japan and other markets throughout Asia and the United Kingdom with respect to regulatory, compliance, trading and operations. Prior to joining Schulte Roth & Zabel, Brad served for 12 years in various in-house roles, including as general counsel and chief compliance officer of investment advisers ranging from multibillion-dollar funds to start-ups, and as a member in the asset management group of a leading investment bank.

A frequent speaker and writer on the topics of fund operations and regulatory compliance, Brad most recently presented on market terms and regulatory issues for co-investments, regulatory changes to Form ADV and recordkeeping requirements, and other compliance topics for private investment funds. He also recently contributed to Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press) and co-authored "The New AML Rules: Implications for Private Fund Managers" and "JOBS Act Update: CFTC Relief Removes Impediment to General Solicitation," which were published in The Hedge Fund Journal.

Brad received his J.D., cum laude, from Boston College Law School and his B.A., magna cum laude, from Georgetown University.

25th Annual Private Investment Funds Seminar

? 2016 Schulte Roth & Zabel LLP

Partner New York Office +1 212.756.2009 jennifer.dunn@

Practices

Investment Management Hedge Funds Private Equity

Jennifer Dunn

Jenny advises hedge funds, private equity funds (including mezzanine and distressed funds), hybrid funds, funds of funds and investment advisers in connection with their structuring, formation and ongoing operational needs, general securities law matters, and regulatory and compliance issues. Her experience includes structuring and negotiating seed and strategic investments, advising investment managers regarding the structure and sale of their investment management businesses and the structure of their compensation arrangements, and representing investment managers in connection with managed accounts and single-investor funds.

Recognized by The Legal 500 United States, Expert Guide to the World's Leading Banking, Finance and Transactional Law Lawyers (Investment Funds) and Expert Guide to the World's Leading Women in Business Law (Investment Funds) and as an IFLR 1000 "Rising Star" (Investment Funds), Jenny co-authored Hedge Funds: Formation, Operation and Regulation (ALM Law Journal Press) and recently presented at conferences on topics including compliance issues, hedge funds and management company structures, and considerations for emerging hedge fund managers.

Jenny earned her J.D. from Columbia University Law School, where she was a Harlan Fiske Stone Scholar, and her B.A., cum laude, from the University of Pennsylvania.

25th Annual Private Investment Funds Seminar

? 2016 Schulte Roth & Zabel LLP

Seetha Ramachandran

Special Counsel New York Office +1 212.756.2588 seetha.ramachandran@

Practices

Litigation Bank Regulatory Financial Institutions Regulatory & Compliance Securities Enforcement White Collar Defense & Government Investigations

Seetha focuses on litigation, anti-money laundering and OFAC compliance, banking and securities enforcement, white collar criminal defense and regulatory investigations, and asset recovery for victims. As a former deputy chief in the Asset Forfeiture and Money Laundering Section (AFMLS), Criminal Division, U.S. Department of Justice, Seetha has expertise in matters that include allegations of violations of the Bank Secrecy Act (BSA), complex money laundering, economic sanctions, and civil and criminal forfeiture. During her tenure at AFMLS, she served as one of the first co-heads of the Money Laundering and Bank Integrity Unit, where she supervised a broad range of investigations and prosecutions of global financial institutions, including HSBC, MoneyGram, Standard Chartered Bank and ING, as well as emerging areas of money laundering and BSA enforcement such as online payment systems and virtual currencies. Seetha also worked closely with state and federal banking regulators and U.S. Attorneys' offices nationwide. Prior to her appointment at AFMLS, Seetha served as an Assistant U.S. Attorney for the Southern District of New York, where she worked in the Complex Frauds, Major Crimes and Asset Forfeiture units, investigating and prosecuting bank fraud, mail and wire fraud, tax fraud, money laundering, stolen art and cultural property, and civil and criminal forfeiture cases and appeals. She is also a former law clerk for the Honorable Richard J. Cardamone of the U.S. Court of Appeals for the Second Circuit.

The Legal 500 United States has recognized Seetha as a leading lawyer. She has counseled a range of companies on AML and OFAC compliance programs and procedures, including banks, broker-dealers, hedge funds, private equity firms, loan and finance companies, money services businesses, and online payment companies. She is also a frequent public speaker and has presented on topics that include enforcement trends in the financial services industry, emerging payment systems, effective AML programs, asset forfeiture and diversity of the white collar bar. Seetha is the co-author of "The New AML Rules: Implications for Private Fund Managers" in The Hedge Fund Journal, "Federal and State Regulators Target Compliance Officers -- Parts I and II" in The Banking Law Journal and "The Interplay Between Forfeiture and Restitution in Complex Multi-Victim White Collar Cases" in the Federal Sentencing Reporter.

Seetha earned her J.D. from Columbia Law School and her B.A., magna cum laude, from Brown University.

25th Annual Private Investment Funds Seminar

? 2016 Schulte Roth & Zabel LLP

Partner New York Office +1 212.756.2441 gary.stein@

Practices

Litigation Regulatory & Compliance Securities Enforcement White Collar Defense & Government Investigations

Gary Stein

Gary focuses on white-collar criminal defense and securities regulatory matters, complex commercial litigation, internal investigations, anti-money laundering issues, civil and criminal forfeiture proceedings and appellate litigation. He represents public companies, financial institutions, hedge funds, other entities and individuals as subjects, victims and witnesses in federal and state criminal investigations and regulatory investigations by the SEC, SROs and state attorneys general. He has conducted numerous internal investigations involving potential violations of the Foreign Corrupt Practices Act, financial statement fraud, money laundering and other matters, and advises companies on compliance with the FCPA and anti-money laundering and OFAC regulations. As a former Assistant U.S. Attorney and chief appellate attorney in the Southern District of New York, Gary investigated, prosecuted, tried and appealed numerous white collar criminal cases involving money laundering, fraudulent investment schemes, bank fraud, insider trading, art theft, illegal kickbacks, terrorist financing and other financial crimes. His civil litigation experience includes claims of fraud and breach of contract, securities class actions and derivative actions, contests over corporate control, and disputes arising from the sale of a business. He has handled more than 150 appeals in federal and state courts involving issues of both criminal law and procedure and complex commercial law. He has successfully argued 15 appeals in the U.S. Court of Appeals for the Second Circuit and most recently led the firm's pro bono representation in Hurrell-Harring v. State of New York, which resulted in a historic settlement that lays the foundation for statewide reform of New York's public defense system, and for which he received New York Law Journal's 2015 Lawyers Who Lead by Example Award.

Gary is listed as a leading litigation attorney in Benchmark Litigation: The Definitive Guide to America's Leading Litigation Firms & Attorneys, The Legal 500 United States and New York Super Lawyers. He serves on the board of directors of The Legal Aid Society and the board of editors of the Business Crimes Bulletin. He regularly presents on FCPA, insider trading and trading compliance, risk management and crisis management issues at conferences and is an accomplished writer. He is the recipient of two Burton Awards for Achievement in Legal Writing -- in 2008 for co-authoring "The Foreign Corrupt Practices Act: Recent Cases and Enforcement Trends," which appeared in the Journal of Investment Compliance, and in 2015 for authoring "Pension Forfeiture and Prosecutorial Policy-Making," which was originally published in the N.Y.U. Journal of Legislation and Public Policy Quorum. He is also the co-author of the "Scienter: Trading `On the Basis Of'" chapter in the Insider Trading Law and Compliance Answer Book (Practising Law Institute) and of "The New AML Rules: Implications for Private Fund Managers" in The Hedge Fund Journal.

Gary obtained his J.D. from New York University School of Law and his B.A. from New York University.

25th Annual Private Investment Funds Seminar

? 2016 Schulte Roth & Zabel LLP

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